G.R. No. 115245 July 11, 1995
JUANITO C. PILAR, petitioner, vs. COMMISSION ON ELECTIONS, respondent.

FACTS

Petitioner Juanito C. Pilar filed his certificate of candidacy for member of the Sangguniang Panlalawigan of Isabela on March 22, 1992. He withdrew this certificate of candidacy three days later, on March 25, 1992. Subsequently, the Commission on Elections (COMELEC) imposed upon him an administrative fine of Ten Thousand Pesos (P10,000.00) for his failure to file the required Statement of Contributions and Expenditures (SOCE) after the May 1992 elections.
The COMELEC, in its assailed resolutions, found Pilar liable under Section 14 of Republic Act No. 7166. Pilar moved for reconsideration, arguing that he could not be considered a “candidate” obligated to file an SOCE because he had withdrawn his candidacy long before the election and thus never actually participated in the political contest. The COMELEC En Banc denied his petition, prompting Pilar to file this petition for certiorari.

ISSUE

Whether a person who filed a certificate of candidacy but subsequently withdrew it before the election is still considered a “candidate” obligated to file a Statement of Contributions and Expenditures under Section 14 of R.A. No. 7166.

RULING

The Supreme Court DISMISSED the petition and upheld the COMELEC’s ruling. The Court held that petitioner Juanito Pilar remained obligated to file his SOCE despite his withdrawal.
The legal logic is anchored on a plain reading of the law and the application of the statutory construction rule, ubi lex non distinguit nec nos distinguere debemos (where the law does not distinguish, we should not distinguish). Section 14 of R.A. No. 7166 explicitly states that “every candidate” must file the SOCE within thirty days after the election. The law does not qualify this obligation by making a distinction between candidates who actively campaigned and those who withdrew. By its clear and all-encompassing language, the term “every candidate” includes all persons who filed certificates of candidacy, regardless of the subsequent withdrawal.
The Court rejected Pilar’s interpretation that only those who “entered the political contest” by being voted upon are covered. To create such an exception would be to engage in judicial legislation, inserting a condition not found in the statute. The duty to file the SOCE is a mandatory and administrative requirement designed to ensure transparency in campaign financing. This obligation attaches upon the act of filing the certificate of candidacy, which officially places one under the ambit of election laws. The subsequent withdrawal does not extinguish this statutory duty, as the law provides no exemption for it. Therefore, Pilar’s failure to file the SOCE rightly constituted an administrative offense punishable by fine.